Doe No. 59 v. Santa Rosa City Schools

Filing 60

ORDER granting #59 STIPULATION to Continue Fact and Expert Discovery Cutoff Dates. Close of Fact Discovery continued to 4/24/2017. Expert Discovery deadlines continued 14 days. Signed by Judge William H. Orrick on 04/10/2017. (jmdS, COURT STAFF) (Filed on 4/10/2017)

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Eugene B. Elliot, State Bar No. 111475
Ethan M. Lowry, State Bar No. 278831
Kate L. Brown, State Bar No. 308134
BERTRAND, FOX, ELLIOT, OSMAN & WENZEL
The Waterfront Building
2749 Hyde Street
San Francisco, California 94109
Telephone: [phone]
Facsimile: [phone]
Email:
[e-mail]

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Attorneys for Defendant
SANTA ROSA CITY SCHOOL DISTRICT

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UNITED STATES DISTRICT COURT

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JANE DOE NO. 59,

NORTHERN DISTRICT OF CALIFORNIA
Case No. 3:16-cv-01256-WHO

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Plaintiff,
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v.
SANTA ROSA CITY SCHOOLS,
Defendants.

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STIPULATION AND ORDER TO CONTINUE
FACT AND EXPERT DISCOVERY CUTOFF

AND RELATED CROSS-ACTION.

Hon. William H. Orrick

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STIPULATION
Defendant SANTA ROSA CITY SCHOOLS (the “DISTRICT”) and plaintiff JANE DOE NO. 59

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by and through their respective attorneys of record, hereby stipulate as follows:

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1.

The Court originally assigned a Fact Discovery cutoff date of February 14, 2017. The

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Parties requested additional time to complete discovery on February 13, 2017. The Court granted the

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parties proposed stipulated Fact Discovery cutoff date of April 10, 2017.

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2.

Both parties require additional time to complete discovery. Trial is set for August 14,

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The DISTRICT intends to conduct the following further discovery: (1) depose the officers
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2017.

STIPULATION AND ORDER TO CONTINUE FACT AND EXPERT DISCOVERY CUTOFF
USDC Case No.: 3:16-cv-01256-WHO

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involved in the incident.

DOE intends to conduct the following further discovery: (1) depose

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Defendant’s District Representative(s) in accordance with Rule 30(b)(6), and (2) depose Lindsey

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Apkarian.

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4.

The parties therefore respectfully request that the Court extend the Fact Discovery cutoff

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date 14 days to April 24, 2017. This extension will not affect the trial date or any other dates previously

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set by the Court. The parties’ stipulation of extending the Fact Discovery cutoff is contingent on such an

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extension not affecting the trial date.

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5.

Further, Defendant’s expert is unable to provide a written report until April 28, 2017. The

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parties respectfully request that the Court extend the Expert Discovery deadlines 14 days as follows: (1)

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Expert Disclosure: April 28, 2017. This extension will not affect the trial date or any other dates

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previously set by the Court.

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contingent on such an extension not affecting the trial date.

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10.

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In fact, the parties’ stipulation of extending the Discovery cutoff is

The parties respectfully request that the Court approve this stipulation and incorporate its

terms in an Order.

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Dated: April 10, 2017

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BERTRAND, FOX, ELLIOT, OSMAN & WENZEL

By:

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/s/ Ethan Lowry
Eugene B. Elliot
Ethan M. Lowry
Kate L. Brown
Attorneys for Defendant
SANTA ROSA CITY SCHOOL DISTRICT

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Dated: April 10, 2017

HERMAN LAW

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By:
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/s/ Arick Fudali
Arick Fudali, Esq. (Calf. Bar No. 296364)
Daniel G. Ellis, Esq. (Calf. Bar No. 298639)
Attorneys for Plaintiff
JANE DOE NO. 59

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STIPULATION AND ORDER TO CONTINUE FACT AND EXPERT DISCOVERY CUTOFF
USDC Case No.: 3:16-cv-01256-WHO

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ATTORNEY ATTESTATION

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I hereby attest that I have on file all holograph signatures for any signatures indicated by a

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conformed signature (“/s/”) within this E-filed document or have been authorized by all parties to show

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their signature on this document as /s/.

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Dated: April 10, 2017

By:

/s/ Ethan Lowry
Ethan M. Lowry

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STIPULATION AND ORDER TO CONTINUE FACT AND EXPERT DISCOVERY CUTOFF
USDC Case No.: 3:16-cv-01256-WHO

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ORDER

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GOOD CAUSE APPEARING THEREFORE, and the parties’ having stipulated to the same, the

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parties’ stipulation is hereby APPROVED. The Fact Discovery cutoff currently set for April 10, 2017 is

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continued 14 days to April 24, 2017. This extension will not alter or affect the trial date or any other

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dates previously set by the Court.

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Expert Discovery deadlines are continued 14 days as follows: (1) Expert Disclosure: April 28,
2017. This extension will not affect the trial date or any other dates previously set by the Court.

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IT IS SO ORDERED.

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Dated: April 10, 2017
William H. Orrick
UNITED STATES DISTRICT JUDGE

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STIPULATION AND ORDER TO CONTINUE FACT AND EXPERT DISCOVERY CUTOFF
USDC Case No.: 3:16-cv-01256-WHO